Corrective Action Plans

Finding Number 2024-001: Eligibility Determination Process (Material weakness in Internal Control over Compliance and Material Noncompliance – Eligibility) Program: Housing Opportunities for Persons with AIDS Assistance Listing Number: 14.241 Response and Corrective Action Plan: Management agrees with the finding that the internal controls required for this program had material weaknesses. To ensure proper program management, program staff have created appropriate procedures and processes to demonstrate internal controls. These include a manager review of potential clients, a checklist for ensuring that the program collects and maintains required records, and a procedure for collecting and storing third-party documentation for client program intake/eligibility, diagnosis, and income. Anticipated Completion Date: by September 1, 2025 Responsible Person: Tiffany Major, Deputy Director

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Quincy, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: CBIZ CPAs P.C. 53 State Street, 17ᵗʰ Floor Boston, MA 02109 Audit period: July 1, 2023 through June 30, 2024 The finding from the June 30, 2024, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Financial Statement Finding Finding 2024-001: Certain Department Expenditures Exceeding Appropriated Amounts – General Fund – Significant Deficiency Condition: During 2024, it was noted that expenditures in the public safety and education functions exceeded the amounts appropriated by the City Council for the fiscal year. Criteria: Massachusetts general law prohibits the City from incurring liabilities in excess of appropriations in each department with certain specific exceptions, such as snow and ice removal costs, state and county charges, and debt service. Prudent budgetary control and monitoring are essential to ensure compliance with such requirements. Cause: The overspending of these appropriations occurred due to an inadequate internal control system to ensure timely budget amendments. Effect: Overspending appropriations in the General Fund constitutes noncompliance with state law and exposes the City to potential fiscal consequences, as the state may require the City to raise such deficits in the subsequent fiscal year. It may also indicate a weakness in the City's internal controls over budgetary compliance. Recommendation: We recommend that City management strengthen internal controls over budgetary compliance. Management should strengthen its’ procedures throughout the year to monitor budget-to-actual expenditures and ensure timely action, such as requesting formal budget amendments when actual expenditures approach or exceed authorized appropriations. Views of Responsible Officials: The Municipal Finance Office will be implementing procedures to ensure that the Municipal Finance Office and relevant department heads document reviews of budget to actual reports monthly throughout the year, with increased review intervals during June. The purpose of this increased monitoring is to ensure that potential budgetary appropriation deficits are identified in a timelier manner that will allow for any necessary budgetary amendments to be approved by the City Council. Finding 2024-002: Information Technology Controls in Financial Statements – Significant Deficiency Condition: During 2024, we noted the following deficiencies relating to information technology controls in the financial statement reporting process: • User Access Mirroring: When new users are provisioned in the accounting system, access rights are often “mirrored” from existing users without sufficient review of job responsibilities. This practice results in users receiving access to system functions beyond what is necessary for their roles and may compromise segregation of duties. • Privileged Access: A review of privileged user listings indicated access accounts with no exclusionary parameters. • Inadequate Controls Over System Upgrades: When implementing accounting system upgrades, controls over change management including testing, documentation, and approval, were not adequately designed or consistently applied. Instances were noted where upgrades were implemented without thorough pre-deployment testing and formal approval from finance or IT management. Criteria: Best practices and standards for internal control require: • Role-based access provisioning aligned with users’ responsibilities and effective segregation of duties. • The use of exclusionary parameters enhances the ability to monitor system access for unauthorized access. • Robust change management controls over system upgrades, including testing, documentation, and management approval, to ensure system integrity and minimize the risk of errors or unauthorized changes impacting financial reporting. Cause: These deficiencies appear to result from a lack of formalized policies and procedures for user access provisioning and for managing and documenting accounting system upgrades. Effect: The deficiencies increase the risk of: • Unauthorized access or inappropriate transactions due to excessive or incompatible user rights, undermining segregation of duties and accountability. • Errors, omissions, or unauthorized changes introduced during system upgrades, potentially affecting the integrity and accuracy of financial data and financial statement preparation. Recommendation: We recommend that City management: • Implement procedures to provision user access based on individual roles and responsibilities, with documented review and approval to ensure segregation of duties is maintained. This should be evidenced by written approval that is approved by Municipal Finance and Information Technology office. • Enhance the current process of implementing accounting system upgrades, including requirements for comprehensive pre-deployment testing, clear documentation, and explicit written approval from the Municipal Finance Office and the Information Technology office, prior to going “live” with the upgrade. • Periodically review system access and upgrade processes to ensure ongoing compliance with internal control standards. Views of Responsible Officials: The City will keep these recommendations in mind as it works to upgrade its already existing best practice IT control environment. Finding and Questioned Costs – Major Federal Program Audit Criteria or Specific Requirement: Uniform Guidance section 2 CFR § 200.430(g) requires non- Federal entities to maintain records that accurately reflect the work performed by employees whose salaries are charged, in whole or in part, to Federal awards. For employees working on a single Federal program, semi-annual certifications are required to document time and effort. Condition and Context: During testing of 40 payroll transactions for employees charged to the Special Education program, the City was unable to provide semi-annual certifications supporting that salaries and wages were properly allocated to the grant. Cause: The City did not have adequate procedures in place to ensure that required time and effort certifications were retained and readily available for payroll charged to Federal awards. Effect or Potential Effect: Failure to maintain required time and effort documentation resulted in the questioned costs documented below. Questioned costs are reported as follows: AL Number: 84.027 Name of Federal Program or Cluster: Special Education Cluster Questioned Costs: $2,572,675 Recommendation: We recommend the City establish and implement procedures to ensure that semiannual certifications are completed, maintained, and reviewed for all personnel whose salaries are charged to Federal awards. Views of Responsible Officials: This is a questioned cost due to the School Department not having completed certain administrative paperwork, required by grant regulations. We have implemented procedures during FY2025 to address this matter. The required paperwork will be retained on file going forward.

Finding 2024-004: Internal Control over Compliance Type of finding: Internal Control (material weakness) and Compliance (material noncompliance) Recommendation: The County should strengthen its internal controls over year-end financial close and reporting with adopted policies and procedures to ensure compliance with the Report submission portion of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements section. Action Taken: This finding is very similar to 2024-002. So, the action taken will be the same as noted for that finding and is as follows. The new accountants are not anticipating any issues with meeting the deadline of June 30, 2026 for the 2025 audit. As they have been busy implementing the new processes that are mentioned in the action taken plan for finding 2024-001. These new processes will ensure that they are able to meet any audit requirements for the 2025 audit in a timely manner. In addition, they are already making plans to start submitting reports, etc. to the auditor immediately beginning in the first quarter of 2026. Another thing that will help with the completion of the audit by deadline is that the accounting office and Treasurer's office have developed a good relationship and have a great line of communication, which helps in getting tasks completed on time. If there are questions regarding this plan, please call the party responsible listed below. Sincerely yours, Tressesa Martinez County Administrator Conejos County, Colorado

Finding 2024-003: Local Assistance and Tribal Consistency Fund, Assistance Listing No. 21.032, U.S. Department of Treasury Compliance Requirements: Reporting Grant No.: N/A Type of finding: Internal Control (material weakness) and Compliance (material noncompliance) Recommendation: The County should strengthen its internal controls with adopted policies and procedures to ensure accurate financial reporting in compliance with the Reporting Guidance for the Local Assistance and Tribal Consistency Fund. Action Taken: During conversations between the auditor, one of the accountants and myself, it was discovered that the LATCF reporting had been completed by the deadline, but what was reported was not necessarily correct. The accountant will take time to review the reporting guidance for the Local Assistance and Tribal Consistency Fund that is found at https://home.treasury.gov/system/files/136/LATCF-Reporting-Guidance.pdf. This will better equip the accountant with the knowledge they need to complete accurately not just on time. In addition, the accountant will go back and fix the incorrect reporting.

Walla Walla County is taking significant steps to address the recent audit finding regarding inadequate internal controls for compliance with federal requirements. Development of a New Policy To rectify this issue, the county is committed to formulating a new policy specifically tailored to meet federal standards. This development process is already in motion, with the expected completion date set for December 2025. Enhancing Internal Controls We believe that the new policy will significantly improve our internal controls and ensure full compliance with federal mandates. Training Initiatives Additionally, we will seek training opportunities to increase the knowledge of all staff regarding federal programs and compliance requirements, ensuring adherence to these programs and grants.

Views of Responsible Officials and Planned Corrective Action — Grace House has created and will implement the following new controls: a) Every reimbursement request made by any employee will require approval from the Executive Director, Assistant Director, or board of directors vote where appropriate. b) For rental invoices, the immediate supervisor must approve all rental invoices for payment processing before being submitted to the administrative office. If the immediate supervisor is absent, the invoice must be approved by the Executive Director or Assistant Director. c) When a new client invoice is submitted for approval for an existing approved landlord, the invoice along with the traditional client identifying information will be reviewed by both the immediate supervisor and the Executive Director. d) When a new client invoice is submitted for approval for a new landlord, the invoice will be reviewed by both the immediate supervisor and the Executive Director. Each invoice requires a W9 form to validate the legal name, property records verifying ownership matching the legal name on the W9, a picture ID of the individual listed on the W9, and a copy of the agreement if a property management company is listed on the W9 instead of an individual. e) All new clients and landlords will be researched through an investigative software to prove there is no evidence of false identity. f) Grace House has contracted an independent certified fraud investigator to conduct periodic reviews for compliance with fraud prevention policies at least semiannually but beginning quarterly through 2025.

MATERIAL WEAKNESS Segregation of Duties and Control Documentation Recommendation: The University should evaluate their financial reporting processes and controls, including the segregation of duties among its internal staff (including number of internal staff), to determine whether additional processes and controls over the financial records of the University are complete, accurate, and retained to support the University’s financial statement prepared in accordance with U.S. GAAP. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards. Name of the contact person responsible for corrective action: Dr. Sean Huddleston, President & CEO Planned completion date for corrective action plan: June 30, 2025

MATERIAL WEAKNESS Financial Statement Preparation Recommendation: We recommend that management review controls related to financial statement preparation review at the end of each period. Financial statement preparation should include a review of reconciliations and balances to ensure that financial statement line items are properly stated and classified. Internally prepared financial statements should also be thoroughly reviewed by members of the board and management outside the finance department on a periodic (monthly or quarterly) basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards. Name of the contact person responsible for corrective action: Dr. Sean Huddleston, President & CEO Planned completion date for corrective action plan: June 30, 2025

The Neighborhood and Housing department will prepare the CAPER in advance of the reporting deadline and provide a copy to the Fiscal Services Supervisor Senior – Grant Accounting each month for review by Fiscal Services. The CAPER will be supported by ledger detail reports to ensure that amounts reported reconcile to Workday. The Neighborhood and Housing department will prepare the CAPER in advance of the reporting deadline and provide a copy to the Fiscal Services Supervisor Senior – Grant Accounting each month for review by Fiscal Services. The CAPER will be supported by ledger detail reports to ensure that amounts reported reconcile to Workday.

The County will enhance its internal controls over reporting and review federal guidance for reporting under the Coronavirus State and Local Fiscal Recovery Funds.

Finding 2024-01 Financial Close Process Condition: During the audit, it was noted that the Organization lacked a robust financial close and review process. This deficiency resulted in material audit adjustments across key financial statement accounts, including revenue, accounts payable, accrued expenses, deferred revenue, nets assets, and related activity accounts. These adjustments were proposed by the auditors and subsequently recorded by management in order to fairly present the financial statements in accordance with generally accepted accounting principles. The extent and materiality of the adjustments indicate that the Organization's existing closing procedures were insufficient to identify and correct errors prior to the audit. Corrective Actions Taken or Planned: The Organization acknowledges this finding and agrees with the auditor’s assessment regarding the need for a more robust financial close and review process. We recognize that the absence of such a process contributed to the material audit adjustments noted during the engagement. Management and the Board are committed to strengthening internal controls and financial oversight to ensure that future financial statements are materially accurate and compliant with GAAP prior to audit. We are confident that the measures underway will address the deficiency and prevent recurrence. To address this finding, the Organization will implement a comprehensive monthly and quarterly financial close and review process to ensure accuracy, timeliness, and compliance with GAAP prior to the annual audit. Specific actions include: 1. Monthly Close Procedures - Develop and document a formal month-end closing checklist. - Reconcile all key accounts monthly (cash, accounts payable, receivables, accrued expenses, deferred revenue, and net assets). - Require dual review and sign-off from the Accountant (FTM) and Co-Executive Director. 2. Quarterly Financial Review - Conduct quarterly reviews of financial statements and reconciliations with the Treasurer of the Board. - Compare actual results against budget and prior-year trends to identify anomalies early. - Engage an external accountant (FTM) quarterly (if feasible) for review and guidance. 3. Training & Capacity Building - Provide finance staff with training in GAAP reporting and nonprofit accounting best practices. - Implement cross-training to ensure continuity if staffing changes occur. 4. Documentation & Controls - Maintain detailed documentation of all reconciliations and adjusting entries. - Establish a clear approval hierarchy for journal entries, ensuring all significant entries are reviewed by leadership prior to posting. 5. Audit Readiness - By implementing these processes, management will be positioned to present materially accurate financial statements prior to auditor review. - The goal is to minimize, if not eliminate, material audit adjustments in future years. Progress will be tracked by requiring the Finance Committee to review and approve quarterly financial packages. Any discrepancies or deficiencies will be documented and corrective steps taken promptly.

Management has implemented enhanced review processes to ensure accuracy in key accounts and prevent discrepancies. A formal review procedure is now in place to examine journal entries before they are posted.

Management will ensure that the books are closed within 45 days of the end of each reporting period. To support this timeframe, we have put a dedicated team in place. Additionally, a month-end checklist has been established to confirm that all tasks are completed on schedule.

Finding 2024-003 Material Weakness in Internal Control Over Special Tests and Provisions Assistance Listing Numbers 93.224 Health Center Program 93.527 Affordable Care Act (ACA) for New and Expanded Services Under the Health Center Program Federal Agency U.S. Department of Health and Human Services, Health Resources and Services Administration Passthrough Agency N/A Award Number/Year 2024 Criteria FFHC is responsible for keeping adequate supporting documentation of the calculation of patient service fees for those patients who qualify for discounted fees based on family size and household income. FFHC is also required to apply discounted fees accurately based on an approved sliding fee scale that meets federal compliance requirements.Views of Responsible Officials and Planned Corrective Actions Friend Family Health Center Inc. and Affiliates (Organization) will implement the following corrective actions for the fiscal year ending June 30, 2024 to remediate the finding and address the cause of the finding. The Organization will implement the following corrective actions for fiscal year 2024 to remediate the finding and address the cause of the finding. • The Chief Financial Officer (CFO) will be responsible for the implementation of the corrective action plan and will oversee all related finance activities. • FFHC will enforce its current policy and related internal control procedures to ensure that supporting documentation of family size and household income is maintained for all patients that receive discounted patient service fees in relation to the Health Centers Program and Affordable Care Act (ACA) for New and Expanded Services Under the Health Center Program. • FFHC will enforce its current policy and related internal control procedures to ensure that discounted patient service fees are properly calculated and charged based on the applicable approved sliding fee scale. The target date for full implementation of these corrective actions is December 30, 2025. The responsible party for the planned resources will be Wendy Thompson, Chief Executive Officer (312) 682-6110. Our address is 340 E. 51st St., Chicago, IL 60615.

Finding 2024-002 Material Weakness in Internal Control Over Reporting Assistance Listing Numbers 93.224 Health Center Program 93.527 Affordable Care Act (ACA) for New and Expanded Services Under the Health Center Program Federal Agency U.S. Department of Health and Human Services, Health Resources and Services Administration Passthrough Agency N/A Award Number/Year 2024 Criteria FFHC is responsible for preparing and submitting its annual Universal Report and Federal Financial Reports in a timely manner. Views of Responsible Officials and Planned Corrective Actions Friend Family Health Center Inc. and Affiliates (Organization) will implement the following corrective actions for the fiscal year ending June 30, 2024 to remediate the finding and address the cause of the finding. The Organization will implement the following corrective actions for fiscal year 2024 to remediate the finding and address the cause of the finding. The Organization has hired staff with higher technical accounting skills than the previous staff. The following staff have been hired full-time or will be hired soon: Payroll and Benefits Specialist, Grant Accountant, Senior Staff Accountant, Accounts Payables and Receivables Specialist, and a Purchasing Specialist.• The Organization has implemented a new accounting system – Sage Intacct. Additionally, we have implemented a grants project tracking module to better help with grants and contracts reporting and compliance. • All grant related year-end audit procedures have been transitioned to the Grant Accountant who has experience with financial audits and compliance and reporting for City, State, and Federal grants. • The Organization will ensure that Finance personnel receive a minimum of twenty-five (25) hours of training annually of relevant accounting topics including updates to generally accepted accounting principles, generally accepted government accounting principles, nonprofit and governmental financial reporting, and other related accounting trainings. • The Organization will ensure that any personnel involved in financial reporting have the technical expertise to help with the preparation, review, and analysis of the Federal Financial Reports and the Universal Report. The target date for full implementation of these corrective actions is December 30, 2025. The responsible party for the planned resources will be Wendy Thompson, Chief Executive Officer (312) 682-6110. Our address is 340 E. 51st St., Chicago, IL 60615. • The Chief Financial Officer (CFO) will be responsible for the implementation of the corrective action plan and will oversee all related finance activities. • To ensure timely submission of Federal Financial Reports (FFR) to HRSA, Friend Health will implement a robust internal calendar that includes all HRSA reporting deadlines along with earlier internal due dates for preparation and review. Designated financial and grants management staff will be responsible for compiling and verifying the required data well in advance of the submission deadline. Friend Health will conduct regular internal reviews to ensure accuracy, completeness, and compliance with HRSA guidelines. Additionally, staff will be provided with ongoing training on HRSA reporting requirements and utilizing reporting tools or software that streamline the FFR preparation process. These proactive measures will help maintain compliance and prevent future delays. • The Organization will document accounting policies and procedures to reflect the new month-end processes and provide training to staff on current and future policies.

Action Taken: Housing Authority of the County of Chester agrees with the above recommendations and has already instituted policies and procedures designed to address the findings. Please see the list of procedures. HACC Recertification & Documentation Checklist (Quick Reference – 1 Page) 1. Recertification Timeline • Annual: Start process 120 days before due date. • Interim: Complete within 30 days of household change. • Missed/Delayed: Notify Program Manager immediately and document reason. 2. Required Documentation • Income verification (pay stubs, benefits, child support). • Asset verification (bank/retirement statements). • Family composition docs (birth certificates, SSNs). • HUD-required forms. • Use EIV when available; seek third-party verification first. • All docs must be collected within 60 days of effective date. 3. File Standards • Use Resident File Checklist for each household. • Files must include all signed forms & verifications. • Store in approved secure system (electronic or paper). • Retain files 3 years after end of participation (longer if litigation/audit pending). 4. Internal Controls • Supervisory Review: 10% of files checked monthly. • Maintain clear audit trail (date notices, interviews, verifications). • Correct any deficiencies within 30 days. 5. Staff & Training • Staff handling certifications = annual HUD/HACC compliance training. • Document training completion in personnel file. 6. Monitoring • Quarterly compliance report on timeliness & file completeness. • Issues shared with Executive Director and Board. • Policies reviewed annually for updates. Roles • Housing Specialists: Complete recerts & file docs. • Supervisors: Monitor timeliness & review files. • Compliance Officer: Audit & reporting. • Executive Director: Oversight & resources. n Follow this checklist to ensure timely recertifications, complete documentation, and avoid audit findings.

Finding 2024-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended June 30, 2023, management was unable to provide timely year end trial balances in accordance with U.S. GAAP without significant adjusting journal entries required to accurately reflect the underlying accounting transactions. The additional effort needed to reconcile fiscal year 2023 balances resulted in delays in reconciling fiscal year 2024 balances. This finding is was also present in prior year. Recommendation We recommend that individuals overseeing the accounting and finance department continue to review the Organization’s current accounting policies and update existing policies or implement new policies, as needed, to ensure that the trial balances are accurately maintained throughout the year, reconciliations are completed and reviewed monthly or quarterly, as appropriate, and the trial balances and related supporting schedules are prepared and reviewed timely after year-end. Management’s Corrective Action Plan There was significant turnovers in the finance department, including the CFO and the finance director. These turnovers affected the ability of the Organization to produce the information on time for the auditors for the fiscal year 2023 audit. The Organization is working with external consultants to improve the timeliness of reconciliations and audit preparation and recruiting vacant positions. We completed accounting policy changes which will correct the issues noted. Management is confident that the issues that have been noted have been rectified. Contact Person: Cynthia Benton, Chief Financial Officer Anticipated Completion Date: December 31, 2025

Corrective action planned: In reviewing audit finding 2024-001, it was determined that the primary cause for the misapplication of the sliding fee was the need for increased training and oversight. One Health has since taken steps to enhance sliding fee policy and procedure training for all staff, with a focus on Intake and Patient Financial Services staff. One Health also intends to review individual performance of staff by implementing peer and supervisory audits of sliding fee scale applications and data entry. Identification of consistent errors has led to enacting accountability measures to allow for additional coaching and follow-up. Additionally, One Health has reviewed EMR processes and functionality to ensure ease and clarity of data entry to eliminate opportunities for human error. Anticipated completion date: December 31, 2025 Contact person responsible for corrective action: Emily Faricy Associate Vice President - Finance

The Town of Jonesboro acknowledges this audit finding and concurs that, for the reporting period ending June 30, 2024, performance and financial reports required under the State and Local Fiscal Recovery Funds (SLFRF) program were not submitted to the appropriate oversight authorities nor made available to the audit team. This lapse was due in part to a lack of understanding of the federal reporting requirements and the absence of internal procedures to track and manage SLFRF reporting obligations. The Town acknowledges that this noncompliance impeded the auditor’s ability to verify program expenditures and compliance with the applicable provisions of 2 CFR Part 200 and guidance issued by the U.S. Department of the Treasury and the Office of Management and Budget (OMB). To correct and prevent future occurrences of this issue, the Town will implement the following corrective action plan: 1. Immediate Remedial Action: The Town will submit any required SLFRF reports for the 2024 program year as soon as possible, even if past the original deadline. We will also reach out to the U.S. Department of the Treasury or its designated agency to formally communicate the reason for the delay and request guidance on next steps, including potential extensions or waivers. 2. Establishment of Formal Reporting Procedures: The Town is developing internal procedures and deadlines to ensure timely submission of all future federal grant reports. These procedures will include: o A reporting calendar with submission deadlines aligned to OMB and Treasury guidance; o Assigned personnel responsibilities for data collection, performance metrics, and narrative preparation; and o Review protocols by finance and grants administration officials prior to submission. 3. Staff Training and Capacity Building: The Town will seek appropriate training from federal or state agencies or through official SLFRF guidance webinars and 116 documentation to ensure staff are fully informed of compliance and reporting responsibilities under the program.

The Town of Jonesboro respectfully disagrees with the characterization of this finding. While the Build America, Buy America Act (BABA) has been in effect since November 2021, the Town has not received any prior audit findings or notices of noncompliance related to BABA in previous grant cycles or during past administrations. To date, there has been no formal 113 notification or technical assistance provided by federal or state agencies to guide the Town in implementing these requirements in its procurement policies. Nevertheless, the Town fully understands the intent and importance of the BABA provisions, which aim to promote domestic manufacturing and ensure compliance in the use of materials for federally funded infrastructure projects. In light of this finding, the Town will take the following corrective actions: 1. Policy and Procedure Updates: The Town will revise its existing procurement policies to explicitly include compliance requirements for the Build America, Buy America Act, including the use of U.S.-produced iron, steel, manufactured products, and construction materials in all federally funded infrastructure projects. 2. Training and Awareness: Staff involved in procurement, grant administration, and capital infrastructure will undergo appropriate training to ensure a clear understanding of BABA regulations and documentation requirements. The Town will also coordinate with the Louisiana Department of Environmental Quality and the Environmental Protection Agency to obtain relevant training materials and compliance tools. 3. Future Audit Integration: Although the Town has not previously received findings related to BABA, this issue will now be incorporated into internal compliance checklists and future audit procedures to ensure consistent adherence going forward. The Town of Jonesboro is committed to full compliance with federal funding regulations and will implement all necessary improvements to ensure that future federally funded projects align with BABA requirements.

The Town of Jonesboro respectfully disagrees with this finding as presented. While the audit notes delays between the receipt of federal funds and their disbursement, the Town asserts that it is not responsible for managing or operating the federal financial system that governs the authorization, disbursement, or scheduling of funds related to the referenced grant. The Louisiana Department of Environmental Quality (LDEQ) and other relevant governmental entities manage the disbursement platform used for this grant, and Town personnel do not have direct administrative control over its structure or scheduling capabilities. Furthermore, Town staff have not received adequate training or guidance from state or federal administrators regarding the procedural requirements or compliance timelines for the Clear Water State Revolving Fund (CWSRF) program. Despite these limitations, the Town remains fully committed to compliance with federal cash management standards and the Uniform Guidance (2 CFR § 200.305), which requires recipients to minimize the time elapsing between the receipt and disbursement of federal funds. To that end, the Town will take the following corrective actions: 1. Formal Communication with Program Administrators: The Town will engage the appropriate contacts at the Louisiana Department of Environmental Quality and relevant federal partners to clarify disbursement protocols, timelines, and responsibilities under the CWSRF program. 2. Staff Training and Coordination: The Town will coordinate with the LDEQ and/or EPA to request or arrange formal training for municipal staff involved in the administration of federal grant funds, with a focus on cash management and financial compliance procedures. 3. Procedure Development: Following training and clarification from the funding agencies, the Town will develop internal procedures and documentation protocols to ensure that federal funds are disbursed as promptly as administratively possible upon receipt. The Town of Jonesboro affirms its commitment to fiscal transparency, accountability, and compliance with all applicable state and federal grant management requirements. We look forward to working collaboratively with our state and federal partners to improve administrative performance in all future program years.

Department of Housing and Urban Development Audit firm: Paciera, Gautreau & Priest, LLC, 3209 Ridgelake Drive, Suite 200, Metairie, LA 70002. Audit period: Year ended June 30, 2024 The findings from the June 30, 2024, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding – Financial Statement Audit: Finding number 2024-001, Material Weakness in Internal Control over Financial Reporting. Condition: The Abbey did not consolidate a subsidiary in its financial statements. Criteria: Generally Accepted Accounting Principles (GAAP) require that all subsidiaries be consolidated into the parent’s financial statements. Cause: The Abbey lacked adequate internal controls to ensure all subsidiaries were identified and consolidated. Effect: The financial statements did not include the financial position and results of operations of the subsidiary. Responsible Person: Right Reverend Gregory Boquet, O.S.B., Abbot Planned Action: Management agrees with the auditor’s finding that there is a material weakness in internal control over financial reporting due to the non-consolidation of a subsidiary. However, after careful consideration, it has been decided not to implement the recommended procedures to consolidate the subsidiary. Justification: Management believes that the current procedures are adequate, and that the non-consolidation of the subsidiary does not materially affect the financial statements. The costs and resources required to implement the recommended procedures outweigh the benefits, given the subsidiary’s limited impact on the overall financial position and results of operations. Management will continue to monitor the situation and reassess it if necessary. Anticipated completion date: Not applicable, as no changes will be made.

2024-002 Improve Controls and Documentation Over Reporting (Material Weakness – Compliance, Internal Control over Compliance) “During our testing of a sample of two of the quarterly expenditure reports utilizing the Governor’s Office for Emergency Relief and Recovery (GOFERR) funding, we noted the following issues: • The Q1 report included $2,534,152 of expenditures that were attributable to a subsequent period as well as a typographical error in the cumulative total expenditure amount; • The Q2 report included $8,636,710 in duplicative expenditures that were also reported in Q1 as well as a typographical error in the cumulative total expenditure amount; and • Formula discrepancies were noted in both Q1 and Q2 reports, resulting in inaccurate calculations. During our testing of the annual project and expenditure report under the direct portion of ARPA funding we noted a material discrepancy between cumulative expenditures per the general ledger and the amount reported of $94,749. The County attributed these discrepancies to a transition to a new summary process designed to increase reporting efficiency. All reported expenditures were valid and appropriately documented based on testing over allowable costs.” Manager’s Statement of Concurrence or Nonconcurrence: The County recognizes there was discrepancy identified between the GOFERR reporting for the ARPA funding and the County’s general ledger. The discrepancy was a result of changes in reporting requirements and data entry errors that did not reflect an actual discrepancy of project costs or missing funds. The issue was used as an opportunity to improve the County’s internal financial tracking by having the Finance Department support the Facilities and Operations Department with an added reconciliation process to verify the reporting is accurate. The reporting requirements have been better clarified since the inception of the reporting model and seems more stabilized. Corrective Action: The worksheet used to track and calculate the data has been updated. Where possible, formulas have been simplified and streamlined to better match the reporting requirements and use corrected timeframes. The remnant data from earlier iterations that catered to earlier requirements, or understanding of those requirements has been removed. When general ledger data entry requests are delivered to the Finance Department they will be accompanied by the worksheet as supporting documentation so that an added reconciliation may be performed.

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal requirements for allowable activities. Name, address, and telephone of District contact person: Jennifer Larson, Executive Director of Finance 124 E. Lawrence Street Mount Vernon, WA 98273 360-428-6110 Corrective action the auditee plans to take in response to the finding: The district concurs with the finding and has taken corrective action. The employee referenced in the findings is no longer employed by the district. Throughout the months-long investigation performed by OSPI, the district worked to implement changes in our internal controls to ensure strong oversight of Migrant Education Program (MEP) grant compliance, including the eligibility determination process. Changes to internal controls include: • A monthly audit of the families who were visited that month. • A trained program recruiter will conduct the eligibility interviews and home visits. • Recruiter will work with regional trained recruiter for support. • A spot check audit of students determined to be eligible district program director. • Monthly logs from staff identifying students they worked with and services provided. • Monthly meetings between MEP district director and MEP regional program manager to ensure ongoing grant compliance. • Monthly meetings with MEP Parent Advisory Committee for ongoing feedback of services provided. • Appropriate staff including the program director are required to attend Migrant grant training provided by OSPI. We thank OSPI and the Washington State Auditor’s Office for their work and collaboration. We will continue regular monitoring of the Migrant Education Program in the Mount Vernon School district to ensure compliance with all program requirements and only eligible students are being served. Anticipated date to complete the corrective action: August 31, 2025

Corrective Action Plan – Federal Funds Review and Processing Audit Finding Reference: Response to Finding 2024-002: Improvement Control Over Period of Performance for Federal Awards Name of Contact Person and Completion Date: Krystal De Gray, COO of Nashua School District 09-22-2025 Planned Corrective Action: The Nashua School District acknowledges the finding related to the control over the period of performance for federal awards (Finding 2024-002). In response, the district will develop and implement a formal internal procedure to ensure that all purchases funded by federal awards are both placed and received within the established period of performance. This procedure will include appropriate review, documentation, and oversight to maintain compliance with federal grant regulations. To further strengthen internal controls, the Nashua School District will implement a procedure limiting purchases to occur no later than 15 days prior to the grant’s end date. Additionally, all necessary services must be received and completed prior to the expiration of the grant period. Mario Andrade Krystal De Gray Superintendent Chief Operating Officer